Botox Training For Non-Medics Surely Not in the UK?!

Posted on the 31 August 2010 at 09:47

Well it was to be expected!

Hot on the heels of our recent government’s decision that it was okay for anyone in England* who wants to have a go at burning your face off with a CO2 Laser or IPL machine to do so with impunity, along comes cosmetic injectables in the hands of non-medics.

(*Ironically this decision also implies that lasers and IPL are more dangerous in the hands of the Welsh where regulation remains!)

The former and current government’s failure to properly regulate the cosmetic injectable market means that coming to a High Street near you soon could be the local barmaid offering “Botox with a Beer” or perhaps your postie, (he has just had his pension cut after all) could also give you a quick injection along with your letters to boost their incomes. Or maybe this could be the new occupation for all those civil servants the government are about to lay off!

How, you may ask, could this be possible? Well, during a round of internet searching I discovered the following site offering Botox® and dermal filler training to ‘non-medical personnel’.

They state in their home page advertising:

“Despite what you may have heard anyone, even those without prior medical knowledge are able to administer these injections after undertaking a BOTOX® training course or dermal filler training course. We will now explain why.

Medicines and Healthcare products Regulatory Agency (MHRA), is a Government agency who are responsibility for standards of safety, quality and performance. They regulate all aspects of medicines and concur with the DOH that BOTOX® and other injectable medicines may be:

a. self administered
b. administered by an appropriate practitioner
c. administered by anyone acting in accordance with the directions of an appropriate practitioner.

This means that legally anyone can give an injection as long as they are directed to do so by a prescriber before it is administered. The reason that doctors, dentists and nurses have routinely given these in the past is not only due to their knowledge and experience but also as they have been the only practitioner that has been able to obtain insurance to practice.

This is changing rapidly. Non-medical personnel, for example phlebotomists, dental nurses, ODPs, pharmacists, health care assistants, beauty therapists, semi-permanent make-up artists and tattooists are now being offered insurance by well known insurance companies.”

All that you need to do to attend one of their courses it to pass a Level 3 Anatomy and Physiology course which they are about to start offering as well, but which can also be sourced from a multitude of correspondence course providers nationwide.

Before injecting real people on the day you start off with empty syringes and dummies to practice on, so you can supposedly master the techniques. The good news folks is that they do not just give out certificates of competency to anyone, oh no, you actually have to inject 4 people on the day to prove that you are competent to inject – (despite the fact the results of botulinum toxins take up to 2 weeks so adverse effects would not show on the day!!) If you inject less than 4 people you only get a certificate of attendance, but that’s okay, you can still inject people whilst you build up your portfolio of evidence to support your upgrade to a certificate of competence, all whilst not insured, but that’s alright as the consent form you will use states that! (Well that’s me totally reassured then!)

They do state that they cannot supply you with botulinum toxin as you need to have a practitioner write a prescription, but they are able to supply you with practitioners that will do this so you can get the product and inject away!

The really good news though, that will please the GMC, NMC, MHRA and surely the new IHAS Register for Cosmetic Injectable Providers (Quality Assurance Mark) Scheme is that: “...only doctors and nurses have the necessary skills to train you in basic medicine and drug interactions which is included in our course agenda.”; and “ can be assured that you will be taught by the very best in the industry”.


In the testimonials section of their site*, they have a diabetic delegate explaining that he felt confident attending the course and now injecting others as he has injected himself everyday for the last 5 years with insulin!!

He booked on to the dermal filler course and took his wife and 4 friends as models and they then forced him to do the Botox® course, but luckily the Academy was happy for him to enrol on this a few weeks later, (no surprise there then, I’m sure they were happy to take his £1,300 too!) He continues to explain how word is spreading and that he injects friends of friends every moth now.

A beauty therapist also comments: “Now I am trained I can safely say that I will be working with a doctor who will make sure I inject in the way the law says I should.  Thanks The Academy of Cosmetic Training."

Isn’t that great? This is the same “law” that says it is illegal for her to inject a dog but a human is fine!

Another delegate, a tattoo artist explained how: “So far it has fitted in perfectly with my business of body piercing and tattooing.  I use needles every day and it is a different technique to what I was used to but I soon got the hang of it.”

Do you think that as I once sewed a button on my shirt with a needle, they will let me have a go!? It’s a bit of a different technique but I am sure I will get the hang of it too!! 

The questions that really need answering are:

  • WHO IS SUPPLYING THESE PEOPLE? (There are only 3 toxin manufacturers currently licensed - surely they can keep a better eye on their product than this?!)

Well me being me and wanting answers I called them, mystery shopper style!

The insurers are Cathedral Associates Limited – if any of you clinics out there are insured by them, it might be worth cancelling your policy very soon as the premiums could be about to go up as all the mistakes come in from the non-medics! (This is also the same insurance firm that we highlighted as offering insurance for beauty therapists who completed a dermal filler course with James McGrath back in our April 2007 feature article - Beauticians Offering Cosmetic Injectables & Peels.)

Details of the training provided were very vague but it I was given the name of a known RGN from the North West who was involved, but there are most certainly others so I will not name and shame her alone.

A doctor is doing the prescribing, but they refused to give me the name(s), stating their reason being that this encourages people to approach the doctor direct, rather than going through the Academy, something which the doctor(s) does(do) not appreciate. So, MHRA and GMC, now it is your job to continue that part of the investigation as they will prescribe without seeing the client; is that legal for cosmetic  procedures I wonder?!?

The product supplied is BOTOX®. Now I know Allergan will come out with the usual “...we cannot control where our product goes and there are several pharmacies that could be supplying it so it is not our fault” excuse but in fact at last check there are only two pharmacies supplying Botox®, namely Health Xchange and Med-fx or you can source from Allergan direct. I would suggest that Allergan do their investigating and stop this, otherwise I am sure the industry will vote with their feet; there are 2 other good toxins out there in Dysport®/Azzalure® and Xeomin®/Bocouture®. It shouldn’t be that hard to see who has been buying that much more all of a sudden!

Finding out who exactly is training delegates was a little trickier; and unfortunately this information was not forthcoming.

Just to really worry you all though, 17 out of their next 18 courses, which all take place before the end of October 2010 in three locations across the country are fully booked – maybe after all, it really is the government’s way of lowering the dole queue!

This to me goes to demonstrate the ridiculous nature of the current legislative situation of Medical Aesthetics, how can the government, the GMC, the NMC, the MHRA and let’s be honest, the Industry allow this to keep happening.

*Since writing this blog and contacting the company via a mystery shopper telephone call the company’s website has been changed and certain information subsequently removed.

We saved copies of the website during our investigation and screen shots of the FAQs and testimonials will be available via the September Edition of our Gold Members Industry Newsletter. Medical professionals interested in attending courses run by reputable training companies can visit this Cosmetic Training Directory.

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Blog Comment(s) [40]

Never mind the fact that he probably has diabetic retinopathy and neuropathy, if he's been slamming needles into his flabby belly/buttocks for a few years he must be ok to administer Botox!

Fab Equizi

Well done, Martyn, I'm glad I'm not alone thinking this industry is going crazy, due to lack of proper regulation!
What saddens me is that it will require a tragic incident at the hands of one of these "practitioners" for the government to make a move.

Marc Armangue, MD

I can see why this causes so much annoyance, it worries me too. But would it not be better to set the standard of training/experience rediculously high, for example, all the training nurses do that could possibly pertain to Botox injection? I meant they have to start somewhere right?


I have received botox injections over the years from doctors, nurses and trained beauty therapists. As my sister states, who incidentally is a highly regarded psychiatrist, doctors do not administer injections. That job goes to the nurse. Most doctors have not administered an injection since their days training way back at medical school. How many of us have suffered at the hands of a nurse trying to administer an injection only to leave us bruised and sore? I had a nurse administer botox around my eyes just before christmas one year and was subjected to spending the entire christmas with a completely full black eye. I am not talking about a tiny bruise at the site of entry of the needle. I am talking about being left with an entire eye black and blue like I'd been seriously punched in the face. What made matters worse was that when I confronted her about it, she told me it was the third time she'd done it that week!!! I have since then had botox injections from a beauty therapist who has had training from an intensive care cardiac nurse on one of these botox courses and she does a darn sight better job than any doctor or nurse I have been to. Quite honestly I would prefer to go to someone who has has done the training, cares and has an interest in beauty rather than a nurse who thinks she can make an easy buck.


A comprehensive knowledge should be enough! Therre is no greater degree of damage being comitted outside the orthodox medical profession within reason of course-i will repeat comprehensive knowledge should be met within a proper accredited manner. However medical interactions as mentioned are an issue that all affiliates of health care should be familiarised with. It is not for the orthodox medical profession to look for every excuse there is to monopolise and exclude those who could carry out these procedures with equal neglible risk for. It is the most part arrogant to assume and monopolise these procedures. I watched one documentary on these fillers and most accidents had been at that time it was allaged by those in the medical profession. You need to open your mind past your own medical training, as medical schools were largely monopolosed themselves by those big pharmaceutical industrys were they not, you are taught what you are fed, and you are harldy risk free saints.


Hi Martyn,
I couldn't agree more. We run BOTOX and dermal filler training courses aimed at doctors, dentists and nurse prescribers. We work closely with leading cosmetic treatment companies and regularly attend major conferences worldwide to ensure that our skills are at the very forefront of Aesthetic Medicine. I am an active member of numerous industry bodies and associations and uphold the highest standards of clinical excellence. All of this preparation is essential to make sure that we provide medical professionals with adequate training. While some smaller treatments like microdermabrasion are safe to be carried out by non-medical professionals, the idea that unskilled practitioners could be responsible for administering BOTOX treatments is an accident waiting to happen.

Q Clinics

Agreed with Q Clinics. Some small treatments can be carried out by non-medical professionals. We also provide Botox Training for doctors and practitioners in India.

Aesthetic Medicine Courses

I think you'll find that ODP's are far more qualified to undertake Botox training than Nurses and midwives. The ODP training has evolved to an extent where they are found in many hospital departments, including theatres, ITU and HEMS. I think the comment above regarding ODP's as 'non-medical' is an outrage!

R Quinn

I would like to say I am a qualified ODP and have done 1 year of anatomy and physiology and clinical pathaphysiology for a year at university which is more than can be said for the amount that nurses have in their training. I am trained in advanced airway manangement, cannulate, take blood etc, since when did the nursing profession have the rights over injecting people. I work in an acute clinical environment and anaesthetists would much rather work with ODP's than nurses that dable in anaesthetics. We also do 1 year of pharmacolgy, complex drug calculations etc, nurses know nothing about our training or the complexity of it and our extended roles that include central and venous line insertion and othe invasive monitoring and are not qualified in making unfounded claims that other professions are incapable of understanding the principles of injection and contraindications of drugs. Odp's are here to stay

a bates

The ability to use a needle, to be able to inject, is such a small part of a treatment as to be bordering on irrelevant. It is all the other critically important aspects of treatment in which medical professionals have both training and experience that enables them to provide the safest treatments:

Obtaining a medical history. We need to understand not only how to do this, but why we ask the questions we do. How do you illicit specific information, what information would cause you concern and what additional questions would such answers prompt? Some medical conditions might be straightforward insofar as you would not treat. But there are many grey areas that require a degree of clinical judgement that cannot be found outside of the healthcare profession. E.g. Rheumatoid arthritis is contraindicated for fillers but what other autoimmune conditions would you assess to make a clinical decision? Indeed have you illicited this information in the first place? Your Botox(R) client has gentamicin eardrops. Would you be sure to find this out? Would you still provide treatment and if not, when would you? Importantly, why - what is your clinical justification?
Obtaining a valid consent. What are the prerequisites for a consent to be valid? What issues of morbidity and incidence would you consider when formulating consent?
The treatment. Just a small part of the process, and arguably the easy part. It requires a knowledge of anatomy and physiology in addition to being able to use a needle. Perhaps this is not the domain of just doctors and nurses etc.
The aftercare. Problems do happen, sometimes serious ones. Can you deal with them? This often requires a significant amount of expertise and a depth of understanding that is beyond many people, including some healthcare professionals. Can you write a prescription to treat problems? Referring to a GP is often not enough.

Andrew Rankin (RGN. NIP)

As a layman to this area reading this, im afraid a lot of rubbish has been written here! When you talk about medical professionals being needed to provide high standards and the skills to inject, an approved high quality course should give you all the administering skills and specific knowledge one would need to perform a safe treatment! If courses are of poor quality then that is a matter for regulation of these course providers.
Theoretically a doctor should perform a full consult prior to administering therefore the medical side IS being attended to. If this is not happening then this is for the practitioner and provider to comply with and they hold ultimate responsibility for any problems they may incur.
As mentioned Drs and nurses dont always necessarily make for the best administers of botox which is why regulations around this probably haven't been enforced! Further to this, on hospital wards healthcare assistants who are unquailified members of staff take bloods regularly from patients. We are not talking about individuals being doctors to solve any and all medical problems that may arise, a doctor should be involved anyway, and this is stated in guidelines and by the course provider. We are talking about the competence to administer! This should not be limited to a doctor or a nurse, as much as they would like this exclusivity. I cannot see why this provider has been singled out and if they are providing a high quality training program to meet competency standards then they are doing their job. I feel that vested interests are trying to be protected here!

dan AHP professional

The person who trained theese beauticians is Tracey Meharg a nurse from St Helena who is under investigation by the gmc..with out people like her none medics would of been trained, but they are here now and have been de frauded 1,000's of pounds to come in to the industry!


good article, although disagree with ODP's being non medical personnel. I am an ODP and i work alongside RGN's which do the same job as me. i give iv's, IM's i assist during surgery. All the exact same as RGN'S role in theatre. also my manager is an ODP.


I am looking at participating in a course for Botox and fillers. I was hoping for more information on cost and insurancesthat i will require.

Liza Brown

I too am an ODP and work alongside other theatre nurses performing all the same theatre duties as does a nurse, whose syllabus for qualification included to inject via all routes and have been doing this for the past 20 years and have been administering botox and dermal fillers in the medical aesthetic field in various clinics for the past 6 years . Is the ODP course not considered of as good a qualification as that of a nurse or suggesting that the ODP's regulating body is of less importance than the NMC? If we are considered the same in theatres and to the same earning capacity and perform all duties in the same way and manor, whether we scrub, circulate, do anaesthetics or do recovery , or ITU for that matter, whether we take students under our wing, mentor them and assess them, we are actually in the deep soup of it all. We all specialised in this arena of work, injecting consecutively. Yet it seems that we are put in the same category as that of podiatrists and beauty therapists and regarded as not being competent. We are constantly injecting under the direction of a doctor, why then not for botox and dermal fillers? If we are deemed incompetent then we should not be allowed to inject in an operating theatre capacity either! A nurse who in involved in consultations or chaperoning or other arenas of work where injecting is not required regularly is considered to be able to inject just because she bares the title? This is unjustifiable! IT IS UNDERMINING OUR PROFESSION , WHY SHOULD AN ODP DIPLOMA COURSE BE ANYTHING WORTH TAKING THEN?

Sandy Johns

WELL SAID SANDY JOHNS!!! I too am an ODP and also run a clinic for botox and other aesthetic treatments. Mr Roe clearly has no idea what an ODP is. If Mr Roe is going to produce an article such as this he really should do his research more thoroughly. Just for your information Mr Roe ODP's are specifically trained for critical care areas i.e theatres, A&E, and ITU. At my particular trust we also cover maternity, resus and the transfer of critically ill patients to other hospitals by ambulance. Hardly a NON MEDICAL profession!. Unfortunately Mr Roe you are one of the small minded people who thinks only doctors and nurses work in hospitals.

Elaine Oxley

Please be aware that the reference in the blog article to ODPs being 'non-medical personnel' was taken as a direct copy of the written content from the home page of the website for the training company being discussed; Academy of Cosmetic Training. (This was at the time of publication, the company has since ceased trading).

The statement (as reposted below) is not attributable to Martyn Roe.

[Quote]Non-medical personnel, for example phlebotomists, dental nurses, ODPs, pharmacists, health care assistants, beauty therapists, semi-permanent make-up artists and tattooists are now being offered insurance by well known insurance companies.[End Quote]

Lorna Jackson |

It seems that several ODP's are of the opinion that I have said they are not medically qualified. If they re read the article they will realise that that particular section is a direct quote from the Academy of Cosmetic Training Website - not from me! Thank you Elaine for the job specification but as someone who has worked within hospitals and knows many ODP's I am well aware of the role and training it involves. Please re-read the article again and you will understand no slight on your profession was meant by me!
The point of this article was to raise awareness to the public that non medical people such as tattoo artists and diabetics were being offered training, insurance and a remote prescribing service by this company. Since this article was written, GMC, NMC and GDC have all clarified their position on remote prescribing and consultations specifically for the administration of Botox for cosmetic reasons and as such any Doctor, Dentist or Nurse prescribing Botox for administration by someone else without a DIRECT FACE to FACE consultation is deemed to be working outside the guideline of those governing bodies and risk suspension or being struck off.
My personal opinion as someone who has been involved in the industry since the launch of Botox is that no one without prescribing powers should administer the product as occasionally the quick administration of another prescription product may be required to deal with a problem and what happens if the prescribing but not administering person is not available? I know this is rare but it does happen. It also happens with fillers and again I am of the belief that they should be prescription medicines too!

Martyn Roe |

I think what ODP's are saying is that given the level of anatomy and physiology and pharmacology they have to study which is over a year and a higher level than that of a nurse, why are nurses given the right to carry out training in aesthetics?. why does a nurse's qualifications supercede that of an ODP in competence to inject?. ODP's work in advanced anaesthetics, advanced airway management, cannulation, invasive monitoring and more. Why therefore is the ODP deemed as not of the same standing?. I am sure the HPC would not agree that they are registering university educated to degree level substandard health professionals to work in the same areas as nurses. Not all nurses are prescribers so that should not be made the issue as to why ODP's can not do the aesthetic training. There is no justifiable reason, history taking is not an argument for excluding other professions from the training, other health professions have to ask the same questions, history taking is not exclusive to nurses.


Hi i am interesting to do this course i had medical tecnologe degree i do all nurses jop .can i do this course?


I have watched with interest the development of this industry particularly over the past 5 years. There is no way that a non medical trained person can possibly know enough after a one day course. The fillers can have such drastic effects - a necrosis being amongst the worst! The people running the courses teaching beauty therapists are doing so only for commercial gain. Making money on the course price and after on the product supply side. I think it best to go through the DTI to get it stopped. To do so we should all expose the trainers of these courses and have our voices heard.

Sharon Pierce

I am interested i doing this course i am non medical but i am a phlebotomist could you send me any information an a price for the course please thank you

sharon powell

I am wanting to trainin botox and dermal treatments I do not have any qualications apart from english math etc so am I allow to attend a course to be able to start doing this ttrament as a job n if so how much is it n how do I get the products to do this treament .

Michelle murray

Hi I'm a dental nurse looking to see if I would be able to do a Botox course if so could u send me on the information and price list


Hi I'm a staff nurse looking to see if I would be able to do a Botox and filler course if so could u send me on the information and price list

Layla alansari

I am a retired RGN(2007). Can I train and administer Botox

Bev Lock

Hello Im a phlebotomist and would love to train to administer Fillers and botox.. can anyone give me more information please Im from Leeds west Yorkshire


hi, i am a trained beauty therapists, but what level do i need to get on this course? how much does the cost? and where is the course in the uk?


I read this aNd to me it sounds as if someone spent a hell of a long time getting all over qualified while being bitterly over taken by people who dont give a dame about the status quo and set sight on their goals, achieving them in the quickest way possible. The world is full of over qualified medical professionals who seem to constantly make grave mistakes. We are bombarded by images of the rich and famous, who have paid out their micheal jackson noses to the most reputable cosmetic surgeons and highly trained medics and still wind up looking like something from fright night. Any intelligent person willing to alter the way they look for vanity reasons, if honest, will admit that theirs an element of risk, no matter what the proceedure, no matter who the person is,highly trained or not. And I believe its the unspoken rule of the beauty game. Get over it you twisted wench. Your not trying to protect the consumer, you have simply got your nickers in a twist!


I am currently a health care assistant and also trained in taking bloods. I am wanting to a botox and fillers course im wondering if i would be able to do so, also how much would it cost and where in the UK would it be? Thanks


Please can you send me dates of next round of training to administer botox, thank you

Elizabeth S Peters

What qualifications do I need, where and how much are the courses

Donna Starkey

Hello I am wanting to train to do this course but don't have any qualifications apart from my hairdressing level 1,2

Donna Shaw

It is like my thoughts has been voiced about the cosmetic industry. Many of the practitioners are even performing botox treatments without having botox training courses which is a dangerous attempt. It’s high time that government should take steps towards regulating the aesthetics industry.

David Harley


really loved reading your blog ,especially this post and funnily enough I am currently working on my final year journalism project which is a documentary on cosmetic injections in Britain and the rise of them... it would be great if you could get in touch and we can have a quick chat about this matter I'm sure we both have a lot to say..
Look forward to hearing from you

Sukaina Benzakour

Hi could you please send me details of any courses coming up soon and a price please as I am interested thanks


im a hairdresser and have been ingecting botox for a year now and i havent even done the course. my dad is a gp and proscribes the vials for me. i can earn £1000 in a bad week and £2000 in a good week


Hii I have a diploma in cosmetics and I need information about the courses for botox and dermal filler training.thanks

Sawsan wehbe


It's such a shame that your current knowledge regarding other MEDICAL professions is so lacking in accuracy! I am a qualified band 6 health care professional governed by the HCPC (yes that's right, health care PROFESSIONALS council, the clue's in the title) and have over a decades experience as an Operating Department Practitioner, specialising in NEUROSURGERY, CRANIOMAXILLOFACIAL and general head and neck surgery. As an scrub practitioner ODP, I am fully trained to adminster all routes of injection into patients and medication, often assisting in surgery, retracting intricate tissues and organs such as the brain. We perform venepucture, place arterial lines, venous cannulae, catheterisation, airway management and the list is endless. We are the surgeon or anaesthetists hero in their hour of need. Following the Agenda for Change all those years ago, the ODP profession was recognised for the skills it requires and was made a registered profession, now studied at degree level, just as nursing. Our training and experience is intense and we spend the entire undergrad training specialising in these type of skills, so the doctors we work with can rely on us to be there and ahead of their own game by anticipating their next move. Nursing undergraduates are barely exposed to these types of skill opportunity and the day to day awareness of managing medical emergencies such as acute onset of anaphylaxis and subsequent airway management. The statement above states that only doctors, dentists and nurses have the necessary knowledge to be proficient in administering an agent such a Botoxilium. I can assure you, ODP training is both comprehensive in anatomy and physiology...We surgically open patients everyday so we have to be! And we certainly study pharmacokinetics and pharmacodynamics with our PHARMACOLOGY module at university. Anyone lucky enough to get an ODP to administer the toxin can also be reassured by the added bonus that we will be able to keep you alive until the MEDICS arrive thanks to our specialist knowledge. Hmmm, ignorance...
Well it was to be expected!

Anonymous, Member Since 03 July 2018


This is necessary that the government should introduce proper regulations for the non-medics as well as medics before they start their aesthetic practice. They should have proper certifications in cosmetic training UK to qualify for performing the non-surgical cosmetic treatments.

Amelia Alice, Member Since 13 October 2018